Francesca Cappucci - Page 5

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humiliating and arduous experience for * * * [her] * * * and
[her] husband.” Petitioner also points out that the proposed
deficiencies started at $1,727 for 1992 and $9,550 for 1993 and
ended in agreed amounts of zero for 1992 and $315 for 1993. In
that regard, however, respondent does not question whether
petitioner is entitled to administrative costs. Respondent
agrees that petitioner is entitled to such costs, but
only to the amount incurred from the time of the issuance of the
notice of deficiency.2
Petitioner contends that sections 301.7430-2(a) and (b) and
301.7430-3(a), Proced. & Admin. Regs., provide a basis for
allowance of the costs (accountant’s fees) that respondent has
declined to permit. Petitioner contends that those procedural
regulations provide the Court with authority to grant reasonable
costs to petitioner, including the amount that was incurred prior
to respondent’s issuance of the notice of deficiency.
Section 301.7430-2(a) and (b), Proced. & Admin. Regs., sets
forth the requirements and procedures for recovery of reasonable
administrative costs. In particular, section 301.7430-2(a),
Proced. & Admin. Regs., is introductory and generally describes
the contents of the regulation.
2 There is no mention here of notice’s of decision being
issued by the Appeals Office.